AML Policy

Introduction

Chinawine Corporation Limited's (the “Company”) is dedicated to upholding the highest standards of anti-money laundering (“AML”) compliance. Our commitment extends to adhering to all applicable laws and regulations globally to combat money laundering and terrorist financing. This AML Policy outlines the Company’s responsibility for AML and counter-terrorist financing, including the identification of beneficial owners, embargo policies, record-keeping, reporting suspicious activities, and training. It also addresses recent developments related to sanctioned countries.

Scope

This Policy applies to all employees, contractors, and third parties acting on behalf of the Company. The standards outlined here are the minimum requirements based on applicable legal and regulatory requirements.

Objectives

The objectives of this AML Policy are as follows:

• Prevent the Company, its employees, and clients from being misused for money laundering, terrorist financing, or other financial crimes.
• Establish a framework for combating money laundering and financing of terrorism.

Applicability

As mandated by the Anti-Money Laundering Act of 2006, the Company is responsible for ensuring that its subordinated enterprises, branches, subsidiaries, and affiliates in the UK, Israel, and abroad fulfill their legal obligations according to this Act. In cases where local regulations are more stringent than this Policy, the stricter standard must be applied. If any applicable laws conflict with this Policy, the relevant to the Company entity must consult with the local legal department to resolve the conflict. If the minimum requirements in this Policy cannot be applied in a specific country due to local law or non-legal reasons, the Company will refrain from entering into a business relationship, continuing a business relationship, or carrying out transactions. For existing business relations in such a country, the Company will ensure that the relationship is terminated, regardless of other contractual or legal obligations.

Definition of Money Laundering

Money laundering involves participating in transactions aimed at concealing or disguising the nature or origin of funds obtained from illegal activities, such as fraud, corruption, organized crime, or terrorism. Predicate offenses for money laundering are determined by local law. The money laundering process typically includes the following stages:

1. Placement: Illegally obtained funds are introduced into financial or non-financial institutions.
2. Layering: Proceeds of criminal activities are separated from their source through complex financial transactions to obscure the origin of funds.
3. Integration: Laundered proceeds are reintroduced into the economy, reentering the financial system as seemingly legitimate funds.

These stages are not static and can overlap. Financial institutions can be exploited at any point in the money laundering process.

Procedure Manual

Client Identification Procedures

As part of the Company’s AML Policy, we have established procedures to verify the identity of all clients before they receive payout commissions as contractors. Before opening a contractor account for an individual client, the Company will conduct a KYC (Know Your Customer) process, and require satisfactory documentary evidence of the client’s:

• Name
• Address
• Date of birth
• Passport or National ID
• Proof of address
• Any other documentation required by local tax authorities.

Sanctioned Countries and Prohibited Clients

The Company will not open accounts, accept funds, or securities from individuals, entities, or high-risk clients (in terms of money laundering or terrorist financing) without conducting enhanced due diligence. We will conduct well-documented due diligence regarding these prospective clients.

The Company will also continuously monitor and adhere to the latest sanctions lists to ensure compliance with sanctions imposed by relevant authorities. Clients and transactions from sanctioned countries or individuals/entities listed on sanctions lists will be subjected to stringent due diligence and may be declined if necessary.

Currently, the list of sanctioned countries includes Afghanistan, Burundi, Central African Republic, Congo Republic, Cuba, Crimea, Democratic Republic of Congo, Eritrea, Guinea, Guinea-Bissau, Iran, Iraq, Laos, Liberia, Libya, Myanmar, North Korea, Papua New Guinea, Somalia, South Sudan, Sudan, Syria, Vanuatu, Venezuela, Yemen, Zimbabwe.

This AML Policy will be reviewed and updated regularly to reflect changes in regulations, industry best practices, and the evolving landscape of AML and sanctions compliance. All employees and relevant parties are responsible for upholding this Policy and complying with AML Laws. Failure to do so may result in disciplinary action, legal consequences, or termination of relationships with non-compliant clients or entities.